Settlement Agreement

This Settlement Agreement (the “Agreement”) states the terms and conditions that govern the
contractual agreement between [PLAINTIFF] (the “Plaintiff”), and [DEFENDANT] (the
“Defendant”) who agrees to be bound by this Agreement.

WHEREAS, [INSERT RELEVANT DETAILS] (the “Incident”); and

PandaTip: Here, you would insert all the relevant alleged details, any charges that were filed, etc. By way of
example: “The Defendant allegedly ran through a red light without stopping, resulting in an estimated $2,000
damage to the Plaintiff’s vehicle (the “Incident”) and the Plaintiff has filed an action in San Diego County Small
Claims Court to recover such damages.”

PandaTip: You also want to label the incident that led to the damage as is illustrated in the example as the
“Incident” to make it easy to reference throughout the document.

WHEREAS, the Plaintiff and the Defendant agree to settle the matter and avoid any further
litigation.

NOW, THEREFORE, In consideration of the mutual covenants and promises made by the parties
hereto, the Plaintiff and the Defendant (individually, each a “Party” and collectively, the
“Parties”) covenant and agree as follows:
1. DISMISSAL OF PENDING LITIGATION. Within [TIME FRAME] from the date of this Agreement,
the Plaintiff agrees to dismiss or effect dismissal of any claims existing or pending in any
jurisdiction relating to the Incident, including the claim filed on [DATE] in [JURISDICTION] (the
“Pending Litigation”).

PandaTip: If there is no claim that has been filed, you may delete all that has been written starting with
“including…”

2. RELEASE OF FUTURE CLAIMS.

i.The Plaintiff hereby irrevocably releases and forever discharges the Defendant from any future
claims arising from the Incident.
ii.The Plaintiff hereby irrevocably and forever waives all rights it may have arising under the law
with respect to the Pending Litigation and the above release.
iii.The Parties agree and acknowledge that A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS
WHICH THE PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF
EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MAY HAVE MATERIALLY AFFECTED HIS
DECISION TO SETTLE.
PandaTip: This section results in the Plaintiff agreeing not to sue the Defendant in the future regarding the
Incident. However, subsection (c) carves out an exception that allows the Plaintiff to sue if something else comes
to light. Continuing the car example, if the Plaintiff subsequently learns that he was significantly harmed internally
from the accident, then he may sue the defendant based on that, but not for the damage done to the vehicle.

3. SETTLEMENT AMOUNT. In consideration for this settlement and release, the Defendant
agrees to pay the Plaintiff the amount of [SETTLEMENT AMOUNT] Dollars ($[NUMBER]) as full
payment, subject to the terms and conditions of this Agreement. Payments shall be made
according to the schedule attached hereto as Exhibit A (the “Settlement Payments”).
4. TIME IS OF THE ESSENCE. The Parties agree and acknowledge that time is of the essence
with regard to the Settlement Payments.

PandaTip: Stating that “time is of the essence” ensures that the deadlines will be viewed as material terms of the
contract and missing such deadlines will be deemed a material breach of the Agreement.

5. NO MODIFICATION UNLESS IN WRITING. No modification of this Agreement shall be

valid unless in writing and agreed upon by both Parties.
6. FULL INTEGRATION. This Settlement Agreement supersedes any prior agreements,
understandings, or negotiations, whether written or oral.

PandaTip: In other words, this agreement is now the controlling agreement with regard to the Debt and in any
event the terms of this agreement conflict with any others signed previously, the terms of this agreement win out.

7. FURTHER ASSURANCES. The Parties shall make any further assurances as may be
necessary to implement and carry out the intent of this Agreement.

PandaTip: In other words, if needed, the parties will take additional actions in order to ensure that the debt will be
settled so long as the terms of this agreement are followed.

8. VENUE. This Settlement Agreement and the interpretation of the terms herein shall be
governed by and construed in accordance with the laws of the State of [STATE]. The Parties
irrevocably submit to the exclusive jurisdiction of the federal and state courts located in
[COUNTY] County, [STATE].

IN WITNESS WHEREOF, each of the Parties has executed this Debt Settlement Agreement, both
Parties by its duly authorized officer, as of the day and year set forth below.

[PLAINTIFF NAME]
_________________________________ ______________

DATE